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`IPR2014-01175
`U.S. Patent No. 6,968,884
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`NORMAN INTERNATIONAL, INC.
`Petitioner
`
`v.
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`HUNTER DOUGLAS, INC.
`Patent Owner
`
`
`Case No. IPR2014-01175
`U.S. Patent No. 6,968,884
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`
`
`
`
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
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`UNDER 37 C.F.R. § 42.10
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`September 10, 2015
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`In the Notice of Filing Date According to Petitioner (“Notice”) mailed
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`IPR2014-01175
`U.S. Patent No. 6,968,884
`
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`August 12, 2014, the Board authorized the parties to file motions for pro hac vice
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`admission under 37 C.F.R. § 42.10(c). The Notice requires that such motions be
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`filed in accordance with the “Order -- Authorizing Motion for Pro Hac Vice
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`Admission” in Case IPR2013-00639, Paper 7 (“Order”).
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`Patent Owner Hunter Douglas, Inc. (“Patent Owner”) hereby respectfully
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`request that the Board recognize Mr. Fredrick L. Whitmer as counsel pro hac vice
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`during this proceeding. This Motion is not opposed by Petitioner.
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`1. Time for Filing
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`This Motion for Pro Hac Vice admission is filed no sooner than twenty-one
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`(21) days after service of the petition, as required by the Order.
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`2. Statement of Facts
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`The following statement of facts shows that there exists good cause for the
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`Board to recognize Mr. Whitmer pro hac vice.
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`Mr. Whitmer is an experienced litigation attorney, and has been involved in
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`numerous litigations involving patent infringement in District Courts across the
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`country. Mr. Whitmer has experience in jury and bench trials, Markman hearings,
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`and Federal Circuit oral arguments in patent infringement litigation. Mr.
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`Whitmer’s biography is attached hereto as an attachment to his declaration (Exhibit
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`2002).
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`
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`1
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`
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`U.S. Patent No. 6,968,884 is currently asserted against Petitioner Norman
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`IPR2014-01175
`U.S. Patent No. 6,968,884
`
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`International, Inc. in Hunter Douglas, Inc. et al. v. Nien Made Enterprise Co. Ltd.
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`et al., No. 1:13-cv-01412-MSK-MJW (D. Colo.) (the “co-pending litigation”). Mr.
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`Whitmer is counsel for Hunter Douglas, Inc. in the co-pending litigation, and as
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`such, has an established familiarity with the subject matter at issue in this
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`proceeding. In the co-pending proceeding, Mr. Whitmer has reviewed prior art,
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`developed validity arguments, developed claim construction arguments, filed and
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`responded to motions regarding personal jurisdiction, stay, and scheduling. Patent
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`Owner has expending significant financial resources in the co-pending litigation
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`with Mr. Whitmer as counsel, and Patent Owner wishes to continue using Mr.
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`Whitmer as counsel in this proceeding.
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`Further, Counsel for Petitioner does not oppose Mr. Whitmer appearing pro
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`hac vice during this proceeding.
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`3. Affidavit or Declaration of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by the declaration
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`of Mr. Fredrick L. Whitmer (Exhibit 2002), as required by the Order.
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`2
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`Date: September 10, 2015
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`IPR2014-01175
`U.S. Patent No. 6,968,884
`
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`Respectfully submitted,
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`s/Kristopher L. Reed
`Kristopher L. Reed
`Reg. No. 58694
`Kilpatrick Townsend & Stockton LLP
`1400 Wewatta Street, Suite 600
`Denver, Colorado 80202
`kreed@kilpatricktownsend.com
`
`Lead Counsel for Patent Owner
`
`
`
`3
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`
`
`Case No. IPR2014-01175
`U.S. Patent No. 6,968,884
`
`
`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that this UNOPPOSED MOTION
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`FOR PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10 was served
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`September 10, 2015 via electronic service:
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`Kourtney Mueller Merrill
`Perkins Coie LLP
`1900 16th St., Suite 1400
`Denver, Colorado 80202
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`Email: kmerrill@perkinscoie.com
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`s/Kristopher L. Reed
`Kristopher L. Reed
`Registration No. 58694
`Counsel for Patent Owner
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`
`
`
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`
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`Bing Ai
`Perkins Coie LLP
`11988 El Camino Real, Suite 350
`San Diego, California 92130
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`Email: ai@perkinscoie.com
`norman-hd-ipr@perkinscoie.com
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`
`
`Dated: September 10, 2015
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`
`
`
`
`67705902V.1
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